Formal Airspace Change Proposal
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Belfast TMA Classification Change Class E to D ACP Page 1 Belfast TMA Airspace Change Proposal Classification change from Class E to Class D Issue 1.0 January 2016 Prepared by: XXXXXX NATS Airspace Change Assurance Issue Month/ Changes in this issue Year Issue 1.0 07/01/2016 Initial issue submitted to CAA SARG Belfast TMA Classification Change Class E to D ACP Page 2 Table of Contents 1 Introduction 3 2 Justification 4 3 Current Airspace Description 5 3.1 Existing Airspace 5 3.2 Traffic Figures, Aircraft Types and Environmental Issues 6 3.3 Operational Efficiency, Complexity, Delays & Choke Points 6 4 Proposed Airspace Description 7 4.1 Objectives/Requirements for Proposed Design 7 4.2 Procedural and Tactical Usage 7 4.3 Proposed New Airspace/Route Definition & Usage 7 5 Impacts & Consultation 9 5.1 Units Affected by the Proposal 9 5.2 Safety Issues/Analysis 9 5.3 Military Implications & Consultation 10 5.4 General Aviation Airspace Users Impact & Consultation 10 5.5 Commercial Air Transport Impact & Consultation 11 5.6 Environmental Impacts (CO2 and local noise etc) 11 6 Analysis of Options 12 6.1 Do Nothing 12 6.2 Implement the Preferred Solution as consulted upon 12 6.3 Make Changes to Dimensions of BTMA and/or surrounding CAS 12 7 Airspace Description Requirement 13 8 Operational Impact 15 9 Supporting Infrastructure & Resources 16 10 Airspace & Infrastructure Requirements 17 11 Environmental Requirements 20 12 Appendix A: LoA Requirement 21 12.1 Ulster Hang Gliding and Paragliding Club (UHPC) 21 13 Draft AIP Amendments 24 13.1 Belfast Aldergrove 24 13.2 Belfast City 24 13.3 ENR 2.1 FIR, UIR, CTA, TMA 25 13.4 ENR 3.1 Lower ATS Routes 25 13.5 ENR 6 Charts 25 13.6 VFR 1:500,000 and 1:250,000 charts 25 Belfast TMA Classification Change Class E to D ACP Page 3 1 Introduction This ACP is sponsored by NATS. The airspace around Belfast is a complex vertical and lateral patchwork of Class D (CTRs, CTAs and ATS routes) and Class E (BTMA) airspace. Belfast Aldergrove (EGAA) and Belfast City (EGAC) each have a CAA exemption from the UK requirement for ATC to inform pilots when transiting from one class to the other. The exemption means that when an aircraft crosses a boundary from one classification to the other, ATC are not required to inform the aircrew on the RT (this fact is promulgated to air crew in the AIP). This proposal is to change the classification of the two elements of the Class E Belfast TMA (BTMA) to Class D airspace. This will homogenise the BTMA, local CTAs and CTRs into Class D, removing the need for the exemption and making the overall Belfast area logically more safe. Belfast TMA Classification Change Class E to D ACP Page 4 2 Justification The justification for this proposal is the removal of the CAA exemption, so both Belfast Aldergrove and Belfast City ATC units comply fully with UK rules as per CAA requirements with no need for exemptions1. The justification and objective were publicised in Section 4 of the consultation document. 1 The exemption is currently needed because multiple RT transmissions and acknowledgements in a short time would increase ATC and pilot workload to the detriment of safety. Belfast TMA Classification Change Class E to D ACP Page 5 3 Current Airspace Description 3.1 Existing Airspace Figure 1 Current Belfast area airspace classifications (Class E highlighted) Belfast TMA Classification Change Class E to D ACP Page 6 Figure 2 Current Belfast area airspace classifications (extract from CAA report) 3.1.1 Figures 1 and 2 illustrate the complex vertical and lateral patchwork of Class E vs Class D in the vicinity of Belfast. 3.2 Traffic Figures, Aircraft Types and Environmental Issues 3.2.1 The number and type of aircraft using the Belfast airports was agreed with SARG at the FWB not to be relevant to this proposal. There are no environmental issues to be addressed. 3.3 Operational Efficiency, Complexity, Delays & Choke Points 3.3.1 The only specific issue with complexity (ATC and pilot workload) is the removal of the current exemption as described in Section 2 Justification. By homogenising the BTMA airspace to Class D, it will simplify the airspace thus reducing complexity for pilots and ATC alike. Belfast TMA Classification Change Class E to D ACP Page 7 4 Proposed Airspace Description 4.1 Objectives/Requirements for Proposed Design 4.1.1 The objective of this proposal is to change the airspace classification in the BTMA area so that all airspace volumes have the same properties, which would allow for simple RT compliance and the subsequent removal of the exemption. 4.2 Procedural and Tactical Usage 4.2.1 No change to current IFR operations (see Section 5 for Impacts, specifically re: VFR GA traffic). 4.2.2 No change to lateral flight paths or vertical profiles. 4.3 Proposed New Airspace/Route Definition & Usage 4.3.1 The only change would be for both BTMA1 and BTMA2 to be changed from Class E to Class D. 4.3.2 See Figure 3 overleaf for draft chart. Belfast TMA Classification Change Class E to D ACP Page 8 D D D D D D Figure 3 Proposed Belfast area airspace classifications (BTMA Class E now Class D) Belfast TMA Classification Change Class E to D ACP Page 9 5 Impacts & Consultation 5.1 Units Affected by the Proposal 5.1.1 This proposal principally affects Belfast Aldergrove EGAA, Belfast City EGAC and to a lesser extent NATS NERL Prestwick Centre which delegates the BTMA operation to EGAA. 5.1.2 Also affected are Langford Lodge EGAL (unlicensed, no ATSU, infrequently used by one operator, lies within the EGAA CTR) and Newtownards EGAD (air/ground radio, owned/operated by a flying club, lies beneath an EGAC CTA and also BTMA2). 5.1.3 NATS NERL Prestwick Centre supports this proposal as follows (extract from email): Our Unit response to the proposal following Impact Assessment is as follows; Details of Impact/Review Comments: No adverse comments from Unit Impact Assessment process participants – proposal is supported. No NODE, system or CAIT changes required. Will require mapping, MATS Part 2, SIRS and LOA changes. Kindest regards XXXXXXX Prestwick Unit Representative Full email embedded in Word document: XXXXX 5.2 Safety Issues/Analysis 5.2.1 Class D provides a known ATC environment that allows for RT-equipped VFR access. Logically, this is safer than Class E where VFR aircraft may fly without RT, without transponding and without a clearance (i.e. they can be invisible to ATC). 5.2.2 Currently, pilots in contact with ATC do not get informed that they are transiting from Class D to Class E or vice-versa, as per the exemption and the AIP notice. 5.2.3 The single classification for all relevant CAS in the vicinity of the BTMA would remove the need for the CAA exemption previously stated in Section 2. 5.2.4 Full compliance with UK ATC standards is a safety benefit. 5.2.5 Non-RT VFR flights would either need to avoid the BTMA or fly beneath it (below 2,000ft altitude for BTMA1, below 3,500ft for BTMA2). 5.2.6 A mitigation for this impact on non-RT VFR flights would be the negotiation of Letters of Agreement with Belfast Aldergrove and Belfast City ATC, for organised club flying in defined areas of the proposed Class D BTMA under specific conditions. 5.2.7 Embedded in this Word document is the Belfast Aldergrove APSA for the proposed Class E to Class D change (pdf). Belfast TMA Classification Change Class E to D ACP Page 10 5.3 Military Implications & Consultation 5.3.1 The UK MOD has raised no objections to the proposed change. 5.3.2 Text extracted from email response: I can confirm that the reason for the ‘no objection’ return is because it will have no impact on the MOD’s operations. Regards XXXXX DAATM Full email embedded in Word document: XXXXX 5.4 General Aviation Airspace Users Impact & Consultation 5.4.1 IFR flights. 5.4.1.1 No impact – IFR flights are required to obtain a clearance to operate within Class E airspace and the same clearance is required to operate within Class D airspace. 5.4.2 RT-capable VFR flights 5.4.2.1 These airspace users may currently enter, and operate within, the Class E BTMA without clearance and may choose not to contact ATC. 5.4.2.2 VFR flights may not enter any Class D volume, such as CTRs or CTAs, without clearance. 5.4.2.3 Under this proposal, the pilots of all RT-equipped VFR flights would be required to use the RT to obtain clearance to enter (and to operate within) the BTMA in the same way they currently need clearance to enter any CTR or CTA. Without prejudicing pre-flight planning expectations, pilots are just as likely to receive appropriate clearances to use the Class D BTMA as they are for Belfast’s current Class D CTRs or CTAs. 5.4.2.4 The LAA objected to the proposal in principle, and have supplied a letter of complaint to the CAA under the GA Alliance umbrella, regarding the conduct of the airspace change process. 5.4.3 Non-RT VFR flights 5.4.3.1 These airspace users may currently enter, and operate within, the Class E BTMA without clearance. Non-RT VFR flights may not enter any Class D volume, such as CTRs or CTAs, without clearance, which in practice cannot be acquired without RT equipment and a licence.